Subject: Comments on National Policy on Open Standards for e-Governance

Dear Sir,

As members of Palakkad Libre Software Users Society (PLUS
http://plus.sarovar.org), we would like to congratulate the Government
for coming up with a National Policy on Open Standards for
e-Governance.

We support the Free Software Foundation's mission to preserve, protect and promote the freedom to use, study, copy, modify, and redistribute computer software, and to defend the rights of Free Software users. We support the freedoms of speech, press, and association on the Internet, the right to use encryption software for private communication, and the right to write software unimpeded by private monopolies.

In a country like ours with fairly adavanced Information
and Communications Technology, information exchange between the people
and their representatives plays an even bigger role. If tools needed
for this interaction are controlled by some and not accessible to the
masses it would have an adverse effect on governence. So it is
heartening to see Indian government leading the way with a policy like
this, which will ensure tools for information exchange with
governement are available and affordable to the masses. This will also
ensure Libre Software users will not be left out from this important
role.

But we are concerned about the efforts by some quarters to subvert
this great initiative by adding loop holes into the policy to allow
patent encumbered and single entity controlled namesake open standards
to be showed in. Section 6.4 of the draft version 2.0 is completely negating the nature of the policy itself. When you have more than one standard in the same domain, it not only increase the effort required to implement all
competing standards, but ensuring perfect interoperability will be
near to impossible as there is going to be some loss of information
during conversion (if both were mapped one to one, there would not
have been a need to have one or more additional standards in the first
place). We request the government of India to remove section 6.4 and
preserve the spirit of the policy.

The Second meeting of the Apex Body on Standards for eGovernance held
on 17th June 2009 introduces "Royalty Free / RAND Standard" standards.
We believe it will severely affect our ability to exchange information
with the Goverment. Paying royalties are not only incompatible with
Free/Open Source Software but it is practically impossible to
implement. Free/Open Source Software are not developed/distributed by
a single entity and it is not possible to track every copy of
Free/Open Source Software, even if payment of royalties is desired.
Even Microsoft has realised this with their recent announcement of
Community Promise for The ECMA C# and CLI Standards and earlier Open
Specification Promise for many of their specifications. We strongly
request the Government of India not to accept these provisions as it
would make it impossible for Free/Open Source implementations of any
standard.

Also the definition of Open Source in Appendix A.11 mentions
intellectual property restrictions. Since we don't allow software to
be patented and trademarks does not come into piture in deciding
whether a software is Open Source or not, it would be better to change
it to copyright resrictions (assuming intellectual property is used as
an umbrella for copyright, patents and trademarks, which itself is a
bad idea).

Once again we congratulate the goverment for coming up with this bold
pro-people policy and request the government to incorporate our
comments.